Criminal law – Proceeds of crime. The Divisional Court quashed production and detention orders made against the claimants, and declared that s 294 of the Proceeds of Crime Act 2002 could not lawfully be used to seize cheques. The requirements of s 346(4) of the Act for the making of the production orders had not been met and, although the lawfulness of the seizure of the cheques did not depend on lawful production orders, s 294 of the Act had not authorised the seizure, as the procedure adopted had not been lawfully available.